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Studies to assess the terrestrial toxicity of aluminium orthophosphate are not submitted for the following reasons:

According to Annex IX of Regulation (EC) No. 1907/2006 (REACH), a study to assess the short-term toxicity to soil organisms may be required. However, such a study is not scientifically justified for aluminium orthophosphate for the following reasons: Aluminium orthophosphate will dissociate to aluminium and phosphate ions (See section 5.1.2 of this dossier). Both aluminium and phosphate are ubiquitous in the environment and are found naturally in soil, water and sediment and are not considered to pose a risk of toxicity to soil macroorganisms. In addition aluminium orthophosphate is not considered to be classified as toxic to aquatic organisms and therefore it can be considered that for terrestrial organisms there is no cause for concern as in general such organisms are expected to be less sensitive than aquatic organisms. It is therefore not considered to be scientifically justified to conduct any testing on soil organisms.